Handbook on CSR in India

www.pwc.in

Handbook on
Corporate Social
Responsibility in
India

Message from the Chairman
CII’s Development Initiative Council

A robust and thriving development sector is central to India’s quest for equitable, inclusive
and sustainable growth. India’s development sector has evolved substantially over the last few
decades and is now witnessing unprecedented interest and investments across the value chain.
With the passage of the Companies Act, 2013 the mandate for corporate social responsibility
(CSR) has been formally introduced to the dashboard of the Boards of Indian companies. The
industry has responded positively to the reform measure undertaken by the government with a
wide interest across the public and private sector, Indian and multinational companies.
The practice of CSR is not new to companies in India. However, what this Act does is bring
more companies into the fold. Also, it is likely that the total CSR spends will increase. What is
clear to many companies is that if this increased spending is to achieve results on the ground
– which is the intent of the Act – then it needs to be done strategically, systematically and
thoughtfully.
It is in this context, that the ‘Handbook on Corporate Social Responsibility in India’ developed
by PwC India for CII can play an important role. The CII being the leading industry body,
through this handbook, envisages equipping companies for this shift of structured engagement
with communities. This handbook is aimed both at companies that are veteran CSR
practitioners as well as those that are just entering the fray. It suggests steps to develop a CSR
strategy and Policy and identifies the key building blocks for initiating and developing the CSR
programs. It walks the CSR practitioner through some of the key choices that may be required
to be made while pursuing CSR objectives and develop an organisation that is socially sensitive
and responsible.
Building a society which provides equal access to opportunities negates disparities and, is a
collective responsibility. This Act presents a unique opportunity to stand up to the challenge. It
is a call for action. And this handbook is a significant step in that direction.

Rakesh Bharti Mittal

Chairman, CII’s Development Initiative Council and
Vice Chairman and Managing Director, Bharti Enterprises

Message from the Mentor and
Chairman Emeritus
Fortis Healthcare Limited

The constitutional structure of the country was laid with an objective of one man equals one
vote, equals one value. However the socio-economic realities of the country still have a long
way to go to match this vision of independent India where today there are many first among
equals. The country presently is under intense debate of developmental growth versus welfare
based development. Our political realities and our economic senses are at cross-roads. How do
we strike a balance between the two? The choices we make today are going to influence our
generations to come.
Every single major policy initiative in this country has been driven with a perspective that an
overwhelming concern for the disadvantaged and marginalised, a multidimensional view of
poverty and human deprivation, the focus on our fundamental rights and the need to expand
opportunities while ensuring its equal distribution are fundamental for achieving strong
human development. But disparity, inequality and the growing divide in our societies define
our existence today. The inclusion of the CSR mandate under the Companies Act, 2013 is an
attempt to supplement the governments efforts of equitably delivering the benefits of growth
and to engage the Corporate World with the country’s development agenda.
Philanthropy and CSR is not a novel concept for Indian companies, however a few
organisations are likely to struggle. The role of civil society in fuelling this change is bound to
be extremely important. With the new corporate resources in their tool bag much will depend
on their ability to innovate and adapt.
The handbook is a guidance document which will facilitate development of CSR mandate
within organisations and help streamline dialogue within the industry. An addendum will
follow with details of the rules once the same have been notified by the Government. The
members of the industry are likely to find their output helpful, informative and enabling.
Confederation of Indian Industry has been in the forefront in sensitising industry on CSR
and creating necessary enablers for promoting CSR for over a decade. I am confident that all
companies will be immensely benefitted from this document too.
I would like to extend my warm appreciation to the PwC team, including Sachin Shukla,
Sharique Ahmad, Anjan Katna, Ankit Gupta and Shankar Venkateswaran who worked towards
the development of this document.

Harpal Singh

Mentor and Chairman Emeritus,
Fortis Healthcare Limited

List of abbreviations
BRR
CSR

Corporate social responsibility

DPE

Department of Public Enterprises

EC

European Commission

ESG

Environmental, social and governance

ILO

International Labour Organisation

ISO

International Organisation for Standardisation

LBG

London Benchmarking Group model

MCA

Ministry of Corporate Affairs

NVG

National Voluntary Guidelines

OECD

Organisation for Economic Co-operation and Development

SEBI

Securities and Exchange Board of India

SME

Small and medium enterprises

SAAS

Social accountability accreditation services

11

The Companies Act, 2013

SGAAP

Social generally accepted accounting principles

14

CSR: Planning and strategising

SROI

Social return on investments

UN

United Nations

23

CSR and SMEs

UNGC

United Nations Global Compact

26

Appendices

UNIDO

United Nations Industrial Development Organisation

WBCSD
4

Business Responsibility Report

World Business Council for Sustainable Development

PwC

Contents
6

What is CSR?

About the handbook
India is a country of myriad contradictions. On the one hand, it has grown to
be one of the largest economies in the world, and an increasingly important
player in the emerging global order, on the other hand, it is still home to the
largest number of people living in absolute poverty (even if the proportion
of poor people has decreased) and the largest number of undernourished
children. What emerges is a picture of uneven distribution of the benefits of
growth which many believe, is the root cause of social unrest.
Companies too have been the target of those perturbed by this uneven
development and as a result, their contributions to society are under
severe scrutiny. With increasing awareness of this gap between the haves
and the have-nots, this scrutiny will only increase over time and societal
expectations will be on the rise. Many companies have been quick to sense
this development, and have responded proactively while others have done so
only when pushed.
Governments as well as regulators have responded to this unrest and the
National Voluntary Guidelines for Social, Environmental and Economic
Responsibilities of Business or the NVGs (accompanied by the Business
Responsibility Reports mandated by the SEBI for the top 100 companies)
and the CSR clause within the Companies Act, 2013 are two such instances
of the steps taken.
According to Indian Institute of Corporate Affairs, a minimum of 6,000
Indian companies will be required to undertake CSR projects in order
to comply with the provisions of the Companies Act, 2013 with many
companies undertaking these initiatives for the first time. Further, some
estimates indicate that CSR commitments from companies can amount to as
much as 20,000 crore INR.
This combination of regulatory as well as societal pressure has meant
that companies have to pursue their CSR activities more professionally.
This handbook attempts to bring together good practices of companies
and grant-making foundations so as to assist companies pursue their CSR
activities effectively, while remaining aligned with the requirements of the
Companies Act, 2013.
This handbook begins by building a common understanding of the concept
of CSR, based on global practices, Indian tradition, and the intent and
provisions of the Companies Act, 2013. It then goes on to bring out the key
aspects of clause 135 of the Companies Act, 2013 and the recently released
draft rules, and highlights its implications to companies.
A major part of the handbook focuses on the ‘what’ and ‘how’ of strategising,
planning, executing and monitoring the CSR activities of companies. It
provides a detailed guidance (rather than prescriptions) for each of these
processes covering the following:
• Objective of the process
• Process owners
• Key inputs and outputs
• Activities or tasks to be covered, including methodology and timelines
• Tools, technical guidance or standards to be employed
It also has a section on what small and medium enterprises, some of whom
will be required to comply with the Act, can do collectively.

What is CSR?
The global context
While there may be no single universally
accepted definition of CSR, each definition
that currently exists underpins the impact
that businesses have on society at large and
the societal expectations of them. Although
the roots of CSR lie in philanthropic
activities (such as donations, charity,
relief work, etc.) of corporations, globally,
the concept of CSR has evolved and now
encompasses all related concepts such as
triple bottom line, corporate citizenship,
philanthropy, strategic philanthropy, shared
value, corporate sustainability and business
responsibility. This is evident in some of the
definitions presented below:
The EC1 defines CSR as “the responsibility of
enterprises for their impacts on society”. To
completely meet their social responsibility,
enterprises “should have in place a process
to integrate social, environmental, ethical
human rights and consumer concerns into
their business operations and core strategy in
close collaboration with their stakeholders”
The WBCSD defines CSR as2 “the continuing
commitment by business to contribute to
economic development while improving the
quality of life of the workforce and their
families as well as of the community and
society at large.”
According to the UNIDO3, “Corporate
social responsibility is a management
concept whereby companies integrate
social and environmental concerns in
their business operations and interactions
with their stakeholders. CSR is generally
understood as being the way through which
a company achieves a balance of economic,
environmental and social imperatives
(Triple-Bottom-Line Approach), while at
the same time addressing the expectations
of shareholders and stakeholders. In this
sense it is important to draw a distinction
between CSR, which can be a strategic
business management concept, and charity,
sponsorships or philanthropy. Even

1 http://ec.europa.eu/enterprise/policies/sustainablebusiness/corporate-social-responsibility/index_
en.htm
2 http://www.wbcsd.org/work-program/businessrole/previous-work/corporate-social-responsibility.
aspx
3 http://www.unido.org/what-we-do/trade/csr/whatis-csr.html#pp1[g1]/0/
4 Brundtland Commission’s Report, 1987

though the latter can also make a valuable
contribution to poverty reduction, will
directly enhance the reputation of a company
and strengthen its brand, the concept of CSR
clearly goes beyond that.”
From the above definitions, it is clear that:
• The CSR approach is holistic and
integrated with the core business strategy
for addressing social and environmental
impacts of businesses.
• CSR needs to address the well-being
of all stakeholders and not just the
company’s shareholders.
• Philanthropic activities are only a part of
CSR, which otherwise constitutes a much
larger set of activities entailing strategic
business benefits.

CSR in India
CSR in India has traditionally been
seen as a philanthropic activity. And in
keeping with the Indian tradition, it was
an activity that was performed but not
deliberated. As a result, there is limited
documentation on specific activities related
to this concept. However, what was clearly
evident that much of this had a national
character encapsulated within it, whether
it was endowing institutions to actively
participating in India’s freedom movement,
and embedded in the idea of trusteeship.
As some observers have pointed out, the
practice of CSR in India still remains within
the philanthropic space, but has moved from
institutional building (educational, research
and cultural) to community development
through various projects. Also, with global
influences and with communities becoming
more active and demanding, there appears
to be a discernible trend, that while CSR
remains largely restricted to community
development, it is getting more strategic in
nature (that is, getting linked with business)
than philanthropic, and a large number of
companies are reporting the activities they
are undertaking in this space in their official
websites, annual reports, sustainability
reports and even publishing CSR reports.
The Companies Act, 2013 has introduced
the idea of CSR to the forefront and
through its disclose-or-explain mandate,
is promoting greater transparency and
disclosure. Schedule VII of the Act, which

lists out the CSR activities, suggests
communities to be the focal point. On the
other hand, by discussing a company’s
relationship to its stakeholders and
integrating CSR into its core operations,
the draft rules suggest that CSR needs
to go beyond communities and beyond
the concept of philanthropy. It will be
interesting to observe the ways in which this
will translate into action at the ground level,
and how the understanding of CSR is set to
undergo a change.

CSR and sustainability
Sustainability (corporate sustainability)
is derived from the concept of sustainable
development which is defined by the
Brundtland Commission as “development
that meets the needs of the present without
compromising the ability of future generations
to meet their own needs” 4. Corporate
sustainability essentially refers to the role
that companies can play in meeting the
agenda of sustainable development and
entails a balanced approach to economic
progress, social progress and environmental
stewardship.
CSR in India tends to focus on what is
done with profits after they are made. On
the other hand, sustainability is about
factoring the social and environmental
impacts of conducting business, that is,
how profits are made. Hence, much of the
Indian practice of CSR is an important
component of sustainability or responsible
business, which is a larger idea, a fact
that is evident from various sustainability
frameworks. An interesting case in point
is the NVGs for social, environmental
and economic responsibilities of business
issued by the Ministry of Corporate Affairs
in June 2011. Principle eight relating to
inclusive development encompasses most
of the aspects covered by the CSR clause
of the Companies Act, 2013. However, the
remaining eight principles relate to other
aspects of the business. The UN Global
Compact, a widely used sustainability
framework has 10 principles covering
social, environmental, human rights and
governance issues, and what is described as
CSR is implicit rather than explicit in these
principles.

Handbook on Corporate Social Responsibility in India

7

Globally, the notion of CSR and
sustainability seems to be converging, as
is evident from the various definitions of
CSR put forth by global organisations. The
genesis of this convergence can be observed
from the preamble to the recently released
draft rules relating to the CSR clause within
the Companies Act, 2013 which talks
about stakeholders and integrating it with
the social, environmental and economic
objectives, all of which constitute the
idea of a triple bottom line approach. It
is also acknowledged in the Guidelines
on Corporate Social Responsibility and
Sustainability for Central Public Sector
Enterprises issued by the DPE in April 20135.
The new guidelines, which have replaced
two existing separate guidelines on CSR
and sustainable development, issued in
2010 and 2011 respectively, mentions the
following:
“Since corporate social responsibility and
sustainability are so closely entwined, it can
be said that corporate social responsibility
and sustainability is a company’s commitment
to its stakeholders to conduct business in an
economically, socially and environmentally
sustainable manner that is transparent and
ethical.”

Why is the CSR clause of the
new Companies Act, 2013 so
critical for SMEs?
By requiring companies, with a
minimum turnover of 5 crore INR,
to spend on CSR activities, the
Companies Act, 2013 is likely to bring
in many SMEs into the CSR fold. This
will usher in a fresh set of challenges
to a sector that is increasingly
being asked by its B2B customers
to comply with environmental and
social standards, while remaining
competitive in terms of price and
quality. Thus, SMEs will have to
quickly learn to be compliant with
these diverse set of requirements and
it is hoped that this handbook will
facilitate their ability to comply with
the CSR clause of the Companies Act,
2013.
5

8

Guidelines on Corporate Social Responsibility and
Sustainability for Central Public Sector Enterprises
-http://www.recindia.nic.in/download/DPE_Guidelines_CSR_Sust.pdf

PwC

Benefits of a robust CSR
programme
As the business environment gets
increasingly complex and stakeholders
become vocal about their expectations,
good CSR practices can only bring in greater
benefits, some of which are as follows:
• Communities provide the licence to
operate: Apart from internal drivers
such as values and ethos, some of the key
stakeholders that influence corporate
behaviour include governments (through
laws and regulations), investors and
customers. In India, a fourth and
increasingly important stakeholder is
the community, and many companies
have started realising that the ‘licence
to operate’ is no longer given by
governments alone, but communities
that are impacted by a company’s
business operations. Thus, a robust CSR
programme that meets the aspirations
of these communities not only provides
them with the licence to operate, but
also to maintain the licence, thereby
precluding the ‘trust deficit’.
• Attracting and retaining employees:
Several human resource studies have
linked a company’s ability to attract,
retain and motivate employees with
their CSR commitments. Interventions
that encourage and enable employees
to participate are shown to increase
employee morale and a sense of
belonging to the company.
• Communities as suppliers: There
are certain innovative CSR initiatives
emerging, wherein companies have
invested in enhancing community
livelihood by incorporating them into
their supply chain. This has benefitted
communities and increased their income
levels, while providing these companies
with an additional and secure supply
chain.
• Enhancing corporate reputation:
The traditional benefit of generating
goodwill, creating a positive image and
branding benefits continue to exist for
companies that operate effective CSR
programmes. This allows companies
to position themselves as responsible
corporate citizens.

Global principles and guidelines
A comprehensive guidance for companies
pertaining to CSR is available in the form
of several globally recognised guidelines,
frameworks, principles and tools, some of
which are discussed below. It must be noted
that most of these guidelines relate to the
larger concept of sustainability or business
responsibility, in keeping with the fact that
these concepts are closely aligned globally
with the notion of CSR.
UNGC
UNGC is world’s largest corporate citizenship
initiative with the objective to mainstream the
adoption of sustainable and socially responsible
policies by businesses around the world. The 10
principles of the UN Global Compact have been
derived from various UN conventions such as
the Universal Declaration of Human Rights,
ILO’s Declaration on Fundamental Principles
and Rights at Work, the Rio Declaration on
environment and development, and the UN
Convention Against Corruption. These principles cover four broad areas:
•

Human rights (support and respect the
protection of international human rights
and ensure that business is not complicit
with human rights abuses)

•

Labour rights (uphold the freedom of association and effective recognition of the
right to collective bargaining, elimination
of all forms of forced and compulsory
labour, effective abolition of child labour
and elimination of description in respect
of employment and occupation)

•

Environment (support a precautionary
approach to environmental challenges,
undertake initiatives to promote greater
environmental responsibility and encourage the development of environmental
friendly technology)

•

Governance (work against corruption in
all forms, including bribery and extortion).

For more details refer the website of UNGC 6

The UN Guiding Principles on Business and
Human Rights
The UN guiding principles provide assistance
to states and businesses to fulfil their existing
obligations towards respecting and protecting
human rights and fundamental freedoms and
comply with the existing laws. These principles
act as global standards for addressing the risk
of human rights violation related to business
activity. In circumstances when these laws
are breached or the guidance is not adhered
to, suitable remedies have also been recommended. The primary focus is on the protection of human rights by both, the state and the
business enterprises, and the principles broadly
outline the manner in which the framework can
be implemented.
For more details refer the website of Office of
the High Commissioner for Human Rights7
ILO’s tripartite declaration of principles on
multinational enterprises and social policy
This is another voluntary declaration whose
adoption by governments, employers and multinational organisations is encouraged, with the
intention of further ensuring labour and social
standards. This is particularly for organisations
that operate across multiple countries. Focus is
on core labour standards such as (i) freedom of
association and the right to collective bargaining (prohibition of discrimination, bonded and
forced labour) (ii) industrial relations (no trade
union restrictions, regular discussions between
management and labour, and the provision of
a forum to lodge complaints in case of labour
standard violation) (iii) employment opportunities (creation of job security, improved living
and working conditions and ensuring that
wages are on par with those of other enterprises in the same country).
For more details refer the website of ILO8
OECD Guidelines: Multinational enterprises
OECD Guidelines for multinational enterprises
elaborate on the principles and standards for
responsible business conduct for multinational
corporations. These guidelines were recently
updated in 2011. They cover areas such as
employment, human rights, environment,
information disclosure, combating bribery,
consumer interests, science and technology,
competition and taxation. They contain defined
standards for socially and environmentally
responsible corporate behaviour, and also provide procedures for resolving disputes between
corporations and communities or individuals
adversely impacted by business activities.

Institute of Social and Ethical Accountability: AccountAbility’s AA1000 series of
standards
This is a series of standards which enable organisations to become accountable, responsible
and sustainable. It consists of the (i) AA1000
accountability principles (AP) standard (ii)
AA1000 assurance standard (AS) (iii) AA1000
stakeholder engagement (SE) standard. Since
these standards have been formulated through
a multi-stakeholder consultation process, they
ensure that those impacted (that is, enterprises, governments and civil societies) stand
to gain. The Vodafone Group Plc has adopted
the AA1000AP standard by focussing on three
broad areas: (i) inclusivity (stakeholder engagement to develop and implement a strategic
approach to sustainability) (ii) materiality
(assess the management effort required for
each material issue and determine the content
of sustainability reports) (iii) responsiveness
(respond with solutions to material issues and
challenges).
For more details refer the website of AccountAbility10
Social Accountability International (SAI): SA
8000 Standard
This is one of the world’s first auditable social
certification standard. It is based on ILO, UN
and national law conventions, and adopts
a management system approach in order to
ensure that companies that adopt this approach
also comply with it. This standard ensures the
protection of basic human rights of workers.
The nine basic elements of this standard include (i) child labour (ii) forced and compulsory labour (iii) health and safety (iv) freedom
of association and the right to collective
bargaining (v) discrimination (vi) disciplinary
practices (vii) working hours (viii) remuneration (ix) management systems. According to
SAAS, there are 695 facilities in India that have
been accredited with this standard. Out of
these, Aditya Birla Chemicals (India) Limited,
Bhilai Steel Plant Steel Authority of India
Limited, Birla tyres, Dr Reddy’s Laboratories
Limited and Reliance Infrastructure Limited
figure prominently in the list of certified facilities within India.
For more details refer the website of SAI11

For more details refer the website of OECD9
6 www.unglobalcompact.org/
7 http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
8 http://www.ilo.org/empent/Publications/WCMS_094386/lang--en/index.htm
9 http://oecdwatch.org/about-oecd/guidelines
10 http://www.accountability.org/standards/
11 http://www.sa-intl.org/index.cfm?fuseaction=Page.ViewPage&PageID=937


9

ISO 26000: Social responsibility

The SROI Network

This is a guidance tool provided by the ISO
which enables organisations to understand the
meaning and significance of social responsibility. It is important to note that this is not a
certification but only a guiding tool. Hence, organisations which comply with these standards
are self-certified. It covers six core areas of
social responsibility, including (i) human rights
(ii) labour practices (iii) environment (iv) fair
operating practices (v) consumer issues (vi)
community involvement and development.
This ensures a holistic approach to the concept
of social responsibility and sustainable development.

The SROI Network is a framework based on
social generally accepted accounting principles
(SGAAP) that can be used to help manage and
understand the social, economic and environmental outcomes created by an organisation or
a person. In order to increase the social value or
impact of a task, SROI helps in understanding,
managing and communicating the social value
that a particular task creates in a clear and
consistent way with customers, beneficiaries
and funders. It also helps in managing risks and
identifying opportunities and raise finances.
It flags potential improvements to services,
information systems and the way to govern the
businesses. By forecasting the value a company
expects to create using SROI, one can identify
the areas where changes are required and a
comparison of performance against forecasts
will help create additional value.

For more details refer the website of ISO12
OECD CSR policy tool
The OECD CSR policy tool aims to help
companies gain insight into their current CSR
activities, assess its value and determine other
CSR activities that can be employed. This policy
tool is based on the OECD Guidelines and the
ISO26000 implementation guidelines. The result of the policy tool is a complete CSR policy,
including an action plan with tasks, responsibilities and a communication strategy plan.
For more details refer the website of OECD13
Global Compact Self-Assessment Tool
The Global Compact Self Assessment Tool is an
easy-to-use guide designed for use by companies of all sizes and across sectors committed
to upholding the social and environmental
standards within their respective operations.
The tool consists of 45 questions with a set of
three to nine indicators for each question. It
consists of a ‘management section’ and four
other sections, including human rights, labour,
environment and anti-corruption that relate to
the principles of the UN Global Compact. The
tool is in line with the UN Guiding Principles
on Business and Human Rights. For a small
company, this tool acts as a measure of the
company’s performance in all areas of the UN
Global Compact and how well these issues are
managed. For a large organisation, this tool
helps to continuously improve existing policies
and systems, engage subsidiaries, suppliers or
other stakeholders, and improves internal and
external reporting.

For more details refer the website of SROI15
The LBG model
Companies across the world adopt LBG’s
measurement model in order to assess the real
value and impact of their community investment to both, the business and society. This
model helps companies to understand the total
amount of cash, time and in-kind invested within the community, and enables them to understand the geographic spread of their community support and the kind of themes supported
such as education, health and arts and culture.
Through this model, companies can track the
manner in which their community programme
supports wider business goals such as building
employee morale or creating reputational
advantages. Also, it helps to measure the difference their programmes make to the community
at large. Under this model, member companies
share data and best practices which in turn help
in the benchmarking process.
For more details refer the website of LBG16

For more details refer the website of Global
Compact Self-Assessment Tool14

12 http://www.iso.org/iso/home/standards/iso26000.htm
13 http://www.oecdguidelines.nl/get-started/creating-a-csr-policy/
14 http://www.globalcompactselfassessment.org/aboutthistool
15 http://www.thesroinetwork.org/117-home/all-regions/167-why-should-i-use-sroi10
16 http://www.lbg-online.net/about-lbg.aspx
17 http://www.mca.gov.in/Ministry/latestnews/National_Voluntary_Guidelines_2011_12jul2011.pdf

10 PwC

National Voluntary Guidelines on Social,
Environmental and Economic Responsibilities of Business
These guidelines rolled-out by the Ministry
of Corporate Affairs in India, were developed
through an extensive consultative process with
the objective of providing a distinctive Indiacentric approach for Indian businesses to understand the nuances of responsible business,
applicable to large and small businesses alike.
They are easy to comprehend and implement,
and encourage businesses to adopt the triple
bottom line approach. These guidelines consist
of nine principles which relate to ethics and
transparency, product life cycle sustainability,
employee well-being, stakeholder engagement,
human rights, environmental stewardship,
responsible policy advocacy, inclusive development and consumer well-being. Each principle
consists of core elements that further articulate
the purpose and sense of each principle. It
also provides an approach for adopting these
guidelines.
For more details refer the website of MCA17

Clause 135,
Companies Act, 2013


11

The Companies Act, 2013
In India, the concept of CSR is governed
by clause 135 of the Companies Act, 2013,
which was passed by both Houses of the
Parliament, and had received the assent
of the President of India on 29 August
2013. The CSR provisions within the Act
is applicable to companies with an annual
turnover of 1,000 crore INR and more, or a
net worth of 500 crore INR and more, or a
net profit of five crore INR and more. The
new rules, which will be applicable from the

fiscal year 2014-15 onwards, also require
companies to set-up a CSR committee
consisting of their board members,
including at least one independent director.
The Act encourages companies to spend at
least 2% of their average net profit in the
previous three years on CSR activities. The
ministry’s draft rules, that have been put
up for public comment, define net profit
as the profit before tax as per the books of
accounts, excluding profits arising from
branches outside India.

The Act lists out a set of activities eligible
under CSR. Companies may implement
these activities taking into account the local
conditions after seeking board approval.
The indicative activities which can be
undertaken by a company under CSR have
been specified under Schedule VII of the
Act.
The draft rules (as of September 2013)
provide a number of clarifications and while
these are awaiting public comment before
notification, some the highlights are as
follows:
• Surplus arising out of CSR activities will
have to be reinvested into CSR initiatives,
and this will be over and above the 2%
figure

List of activities under Schedule VII

Promotion of
education

• The company can implement its CSR
activities through the following methods:
-- Directly on its own
-- Through its own non-profit
foundation set- up so as to facilitate
this initiative

Eradication of extreme
hunger and poverty

Gender equity and
women empowerment

-- Through independently registered
non-profit organisations that have a
record of at least three years in similar
such related activities
-- Collaborating or pooling their
resources with other companies

Reducing child
mortality and
improving maternal
health

Environmental
sustainability

Combating
HIV-AIDS,
malaria and other
diseases

Social
business
projects

And such
other matters
as may be
prescribed

Contribution to
Prime Minister’s
relief fund and other
such state and
central funds

Employment
enhancing
vocational
skills

• Only CSR activities undertaken in India
will be taken into consideration
• Activities meant exclusively for
employees and their families will not
qualify
• A format for the board report on CSR
has been provided which includes
amongst others, activity-wise , reasons
for spends under 2% of the average net
profits of the previous three years and
a responsibility statement that the CSR
policy, implementation and monitoring
process is in compliance with the CSR
objectives, in letter and in spirit. This has
to be signed by either the CEO, or the MD
or a director of the company

Governance
Clause 135 of the Act lays down the

12 PwC

guidelines to be followed by companies
while developing their CSR programme.
The CSR committee will be responsible
for preparing a detailed plan on CSR

activities, including the expenditure, the
type of activities, roles and responsibilities
of various stakeholders and a monitoring
mechanism for such activities. The CSR
committee can also ensure that all the kinds
of income accrued to the company by way of
CSR activities should be credited back to the
community or CSR corpus.

Role of the board and the CSR committee

Form a CSR commiittee

CSR committee

Three or more directors with at least one
independent director

Approve the CSR policy
Ensure implementation of the activties
under CSR

The new Act requires that the board of the
company shall, after taking into account
the recommendations made by the CSR
committee, approve the CSR policy for
the company and disclose its contents in
their report and also publish the details
on the company’s official website, if any,
in such manner as may be prescribed. If
the company fails to spend the prescribed
amount, the board, in its report, shall
specify the reasons.

Business responsibility
reporting

Net worth > 500 Crore INR
Turnover > 1000 Crore INR
Net profit > 5 Crore INR

Role of the board

Reporting

Formulate and recommend a CSR
policy to the board

Ensure 2% spend

Recommend activities and the amount
of expenditure to be incurred

Disclose reasons for not spending the
amount (if applicable)

Monitor the CSR policy from time to
time

The other reporting requirement
mandated by the government of
India, including CSR is by the SEBI
which issued a circular on 13 August
2012 mandating the top 100 listed
companies to report their ESG
initiatives. These are to be reported
in the form of a BRR as a part of the
annual report. SEBI has provided a
template for filing the BRR. Business
responsibility reporting is in line with
the NVG published by the Ministry
of Corporate Affairs in July 2011.
Provisions have also been made in
the listing agreement to incorporate
the submission of BRR by the relevant
companies. The listing agreement
also provides the format of the BRR.
The BRR requires companies to report
their performance on the nine NVG
principles. Other listed companies
have also been encouraged by SEBI
to voluntarily disclose information
on their ESG performance in the BRR
format.


13

CSR
Planning and
strategising

14 PwC

CSR: Planning and
strategising
The first step towards formalising CSR
projects in a corporate structure is the
constitution of a CSR committee as per the
specifications in the Companies Act, 2013,
clause 135.

Background
Clause 135 of the Companies Act, 2013
requires a CSR committee to be constituted
by the board of directors. They will be
responsible for preparing a detailed plan
of the CSR activities including, decisions
regarding the expenditure, the type of
activities to be undertaken, roles and
responsibilities of the concerned individuals
and a monitoring and reporting mechanism.
The CSR committee will also be required to
ensure that all the income accrued to the
company by way of CSR activities is credited
back to the CSR corpus.

This is an excellent starting point for any
company new to CSR. In case a company
already practices CSR, this committee
should be set up at the earliest so that it
can guide the alignment of the company’s
activities with the requirements of the Act.
For effective implementation, the CSR
committee must also oversee the systematic
development of a set of processes and
guidelines for CSR to deliver its proposed
value to the company, including:
•

•

repetitive processes such as the
annual CSR policy, due diligence of
the implementation partner, project
development, project approval,
contracting, budgeting and payments,
monitoring, impact measurement and
reporting and communication

A set of such enabling processes, their
inter-relationships and the sequence in
which they need to be developed have been
identified below:

one-time processes such as developing
the CSR strategy and operationalising
the institutional mechanism

CSR processes

1

Developing a CSR strategy
and policy

+

Operationalising the
institutional mechanism

2

Due diligence of the
implementation partner

+

Project development

3

Project approval

+

Finalising the
arrangenment with the
implementing agency

Companies Act, 2013, Clause 135: CSR
committee requirements
•

A CSR committee of the board should
be constituted. It should consist of at
least three directors out of whom at
least one is an independent director.
This composition will be disclosed in
the board’s report as per sub-section
(3) of section 134.

•

The CSR committee shall:
-- formulate and recommend a CSR
policy to the board, indicating the
activities as specified in Schedule
VII of the Act
-- recommend the amount of
expenditure to be incurred on the
activities indicated in the policy

Project implementation

4

Progress monitoring
and reporting

-- monitor the CSR policy regularly

5

Impact measurement

+

Report consolidation
and communication


15

While developing these processes, no
standard set of recommendations exist for
all companies. However, an overview of the
required details, the activities required to be
completed for each of these processes along
with some additional guidance on critical
issues has been provided below:

•

CSR policy refers to what the company
expects to achieve over the next year.
This is aligned with the requirements of
the Companies Act, 2013 .

•

Programme refers to a sector or an
issue that the company proposes to
address through its CSR. This can,
for instance, be ‘education of the girl
child’ or ‘agriculture development’.
Programmes will be clearly outlined in
the company’s CSR strategy.

•

Programme goals will be achieved
through a series of individual projects
and, a project refers to a set of
interventions, typically in a specific
geography and addressing a specific
stakeholder group, with a definite set of
goals, beginning and end and a budget
attached to it.

Step one: Developing a CSR
strategy and policy
Purpose
The Companies Act, 2013 requires every
company to put out its CSR policy in the
public domain. The guidance provided
in the Act and the draft rules on what
constitutes a CSR policy are that it should:
•

exclude normal business activities of
the company

•

contain a list of the CSR projects or
programmes which the company
plans to undertake during the
implementation year

•

Each project in turn will consist of
a number of activities. All of which
contribute towards the project goals.

Frameworking CSR strategy

While specifying the annual report
requirements, the draft rules go on to say is
that the company must provide:

An effective CSR strategy should articulate:
•

who it wishes to address i e the target
group

•

a brief outline of its CSR policy,
including ‘the statement of intent
reflecting the ethos of the company,
broad areas of CSR interest and an
overview of activities to be undertaken’

•

where it wishes to work i e the
geography

•

what sectors or issues it wishes to
address

a web link to the CSR policy including
‘the full list of projects, activities
and programmes proposed to be
undertaken by the company’

A brief understanding of these terms is
outlined below:

•

Since most of the development requires
long-term commitments and their impact
often takes a while to accrue, a good CSR
practice requires that a company that is
serious about its CSR should develop a
long-term (three to five years) vision and
strategy which is reviewed annually and the
activities and budgets are planned on an
annual basis. The latter will comply with the
CSR policy requirements of the Companies
Act, 2013.
To avoid confusion regarding terms like
policy, strategy, project and programme, a
brief explanation has been provided here:
•

CSR strategy refers to what the
company expects to achieve in the next
three to five years and incorporates the
vision, mission and goals on a broader
level. It also entails how it plans to
achieve these in terms of organisation
and approach.

16 PwC

Target group: While development and
welfare programmes in India address all the
citizens, the focus is on the disadvantaged,
marginalised and excluded. Marginalisation
in India is primarily on the basis of gender,
disability, ethnicity and location. This leads
to social and physical exclusion of such
groups from all kinds of development.
Engaging the marginalised in India is
further complicated due to language and
literacy variances, information asymmetry,
infrastructure constraints, geographical
challenges and cultural barriers to name
a few. The CSR strategy should ideally
indicate which of these marginalised groups
it proposes to target.

Geography: The Companies Act, 2013
encourages companies to target their CSR
interventions in their local region. While
this is an obvious choice for companies that
are in manufacturing, those in the services
sector (like banking and telecom) with a
wider footprint have no concentrated local
region. Companies must decide whether
their CSR activities will be focused on a
few geographies (this can be around their
plants or in specific backward districts) or
whether they will prefer to particularly work
anywhere in India.
Sector and issue: Sector refers to the
development area that the company wishes
to focus on; typically, health, education,
livelihood, environment, and so on.
Issue refers to a specific aspect of a sector
for example, primary education in the
education sector, skills development or
social enterprise in the livelihoods sector.
It is important for a company to determine
which sector and issues it will focus on to
ensure significant positive impact. Also,
the reporting format in draft rules of the
Companies Act, 2013 requires that the
company report against the sector making it
all the more important.

Process
Objective: Developing the CSR strategy and
policy.
Process owners: The CSR committee
Inputs:
•

Guidance from the board

•

Companies Act requirements

•

Corporate business strategy, plan and
supply chain

•

Development priorities: both, national
and wherever the company has
business interests

Output(s): the CSR policy document and an
indication of sectors and issues, geographies
and a profile of the beneficiaries.

•

Activities
•

Reviewing the past as well as the
current CSR activities and examining
their alignment with Schedule VII of
the Companies Act, 2013.

•

Studying the publicly available
information on national and local
development priorities.

•

Meeting development experts in the
government as well as the NGOs to
understand priorities and identifying
potential areas of intervention.

•

Conducting internal meetings with
business leaders to establish the
relevance of potential CSR activities to
the company’s core business.

•

•

Studying the good CSR practices
of other companies and their
achievements.

Step two: Operationalising the
institutional mechanism

Determining the implementation
mechanism:
-- grant-making or direct
implementation

Purpose

-- institutional mechanism: in-house
department, corporate foundation,
partnerships with other NGOs
•

•

Annually developing a CSR policy in
line with the Companies Act, 2013 rules
that defines programmes, geographies
and budgets for the following financial
year, aligned with the strategy and
ensuring that the 2% requirement of
funds allocation is met

In order for a corporate to gain the greatest
leverage and a strategic advantage through
the investment of intellectual and financial
resources, they are required to select their
implementation mechanism. In terms of
implementation mechanism, a company has
several options, which are permitted under
the CSR draft rules:
•

-- an in-house CSR department

Establish methods for monitoring and
reporting

Tools, technical guidance and
standards to be used:

Self-execution through:
-- a company foundation with execution
capabilities

•

Making grants to an independent
implementation partner (which has a
track record of at least three years).

•

The grants can be made:

•

The 10 principles of the UN global
compact

•

UN guiding principles on business
and human rights

-- directly by an in-house CSR
department

•

ILO tri-partite declaration of
principles on multinational
enterprises and social policy

-- through the company’s grant-making
foundation

-- beneficiaries

•

OECD CSR policy tool

-- KPIs

•

Global compact self assessment

•

Clause 135, Companies Act, 2013

Developing a CSR strategy that defines
for the next three to five years, what
the company’s CSR activities will cover
in terms of:
-- vision and mission
-- sectors and issues
-- geographies: states and districts

The factors that a company needs to
consider while deciding between in-house
execution and grant-making (whether
by the department or the company
foundation) are as follows:

Decision criteria

Grant making

Self execution

Availability and access to

Preferred when there is an easy availability and
access to the implementation partners (in the target
geography working on identified sector and issue) who
can work towards the objective that the company wants
them to pursue.

Preferred when there is a lack of availability and
access to the implementation partners (in the
target geography working on identified sector and
issue) who can work towards the objective that the
company wants them to pursue.

Customisation

The flexibility of customising a CSR project to suit the
company needs is low to medium.

The flexibility of customising a CSR project to suit
the company needs is high.

Cost of implementation

Implementation partners are more likely to have lower
costs due to their concentrated focus in pursuing
development activities, cumulative time spent on
the field, cost of human resources deployed and
in general operational efficiencies. Fixed costs are
usually averaged down as the implementation partners
usually try to tap multiple sources of funding including
government assistance.

Overheads are usually higher and economic
efficiencies lower (at least during inception and
growth phases). Higher fixed costs are involved.

Control

Low to medium levels of control over day to day
activities, efficiencies and outputs.

High levels of control over day to day activities,
efficiencies and outputs.

Building expertise

Project management know-how is sufficient and indepth domain knowledge of development issues is not
expected.

Project management know-how is required along
with in-depth domain knowledge of development
issues.


17

It must be noted that whatever
implementation mechanism the company
chooses, it must have a basic CSR
department in place to support the CSR
committee. The role and structure of the
department will be determined by the CSR
committee.

Process

Selecting legal structure of the
company foundation

Inputs: The CSR strategy

Many companies have set up their own
foundations (a term used loosely to describe
a non-profit entity promoted by a company)
to implement their CSR activities. The
advantages that they see in this are:

•

creation of a separate legal entity or a
CSR department for CSR activities

•

other institutional mechanisms
to align the accounting, finance,
administration, HR and IT systems with
CSR activities

•

•

It enables leveraging of funds from
other sources i e the government
schemes and other foundations.
Typically, profit organisations are not
eligible for such funds.
Since the skills, job titles, career paths
and cost structures required for the
execution of CSR projects are quite
different from a company’s operations,
a separate foundation enables the
company to keep these distinct.

Under the draft CSR rules, an entity
that a company sets up to facilitate the
implementation of its CSR activities is to
be registered in India as a trust, society,
or a non-profit company under section 818
of the Companies Act, 2013. Non-profit
organisations in India are:
•

self-governed by a board of trustees or
a managing committee or a governing
council, comprising individuals who
generally serve in a fiduciary capacity

•

Output(s):

Activities:
•

Selecting the organisation model for
the CSR implementation: in-house
versus outsourced and its legal entity
(trust, society, Section 819 company ,
in-house department, etc)

•

Identifying the implementation model
(grant making, direct project execution,
etc)

•

•

•

intended to benefit others outside the
membership of the organisation

•

Objective: Establishing a legal entity and
aligning the accounting, tax, finance,
administration, HR and IT systems to deliver
the commitments made in the CSR policy.

prohibited from distributing a
monetary residual to its members

A detailed comparative analysis of the
three choices of non-profit legal structures
is attached in Appendix 1: Comparative
analysis of the three choices for legal
entity.

Formalising the job description,
the roles and responsibilities and
the reporting relationships for the
CSR team (whether in-house or in a
foundation)
Integrating budgeting, procurement,
payments and reporting for CSR with
the existing finance, administration
and IT systems

Step three: Due diligence of the
Purpose
Due diligence refers to the process a
company undertakes to determine the
risks as well as the benefits of working
with a potential implementation partner.
This process has to be sufficiently robust to
ensure that a company’s implementation
partners have the reputation, competence
and integrity to deliver effective
programmes on the ground.
It begins as soon as the discussions with
the implementation partner suggest that
there is prima facie interest of both parties
to enter into a partnership. A detailed
due-diligence is essential for large and
long partnerships but may be brief for a
relatively small or opportunistic partnership
opportunity.
The due diligence process consists of five
primary areas for investigation:
•

competence of the implementation
partner

•

identity

•

management

•

accountability

•

transparency and financial capability

These have been outlined below:

Analysing accounting systems and
chart of accounts and make required
changes to record all expenses
appropriately. Establish a method of
allocation for the expenses (or assets
created) that are partly for the CSR
and partly for business or employee
use.

•

To be tailored as per corporate
requirements

18,19 The non-profit organization formerly known as Section 25 companies are now called Section 8 companies after the introduction of Companies Act, 2013.

18 PwC

Issue

Sub-issue

Description

Competence of the
implementation
partner

Geography

Capacity, expertise and the number of years of experience with the geography under consideration

Sector

Capacity, expertise and the number of years of experience with the sector under consideration

Issue

Capacity, expertise and the number of years of experience with the issue under consideration

History of existence

The number of years the implementation partner has been in existence

Legal identity

The organisation is registered either as a trust, a society or Section 8 company, a charitable company,
a co-operative society or is unregistered

Affiliations

The desired level of affiliation with governments, local administration and international bodies

Litigations

Any ongoing litigation

Composition of the board

Number of members, advisors, term of members and advisors and board renewal procedures

Profile of the board
members and advisors

Bios of the members on the board, their number of years and depth of experience and relevant
achievements

Diversity in expertise

The expertise available at the disposal of the board for development activities

Board meetings

Regularity of meetings, attendance records and recent topics of discussion

Vision, mission and
strategy

The management outlines its vision, mission and strategy in its operational plans or other documents.
These plans are communicated to all relevant employees

Experience of the
management

The management personnel responsible for the day-to-day activities have the necessary depth of
experience and skill set to manage the current and the future growth plans.

Conflict of interest

Any conflict of interest between the board members, the advisors or the management personnel with
the company. There is no conflict of interest with the local governments.

Transparency

Awareness of the disclosure and the transparency requirements for all stakeholders (including
regulators and funders) like periodic reporting, external audits and ratings

Financial statements

Availability of audited financial statements

Adequacy of reserves

A formalised and institutionalised system for keeping reserves for times of financial need

Section 12A registration

Status of Section 12A registration

80G registration

Status of 80G registration.

FC(R)A registration

Status of the registration with the Foreign Contribution (Regulation) Act 2010.

Identity

Management

Transparency

Financial capability

A more detailed due-diligence can also
undertake the evaluation of the following
five issues:

•

•

organisation structure

•

•

operations, systems and processes

•

human resource

Activities:

•

financial capability

•

risk management

Output(s):

•

CII and Credibility Alliance’s guidelines for
identifying NGO partners are mentioned in
Appendix 4.

Process
Objective: Selecting the implementation
partner.

•

discussions with communities, board,
staff, other funders, local government
officials, local leaders or influencers,
auditors

Establishing a due diligence criteria
to evaluate the implementation or
concept development agency including
its incorporation, permits and licenses,
systems, processes, public image,
management, team deployment,
track record, financial soundness,
competence level, presence in desired
geography, compatibility with company
CSR policy and any conflicts of interest.
Establishing a due diligence criteria
for evaluation and empanelment of
private funders for partnership and
joint projects.

•

Evaluating the partnership
opportunities for its risks and benefits.

the CSR strategy and policy

•

a due diligence report

•

Process owners: The CSR department or
Company Foundation
Inputs:

studying the books of accounts and the
auditor’s report

Step four: Project development
Purpose
The CSR strategy of a company will be
implemented through a series of projects
which will have definite beginnings, ends,
expected outputs and outcomes as well as
budgets associated with it. These projects
may be of a short duration (a few months)
or multi-year.
A company may choose to implement
projects through its in-house teams or
in partnership with other agencies or a
combination of both. Whatever path it
takes, it is important for the project to be
developed clearly with distinct baselines,
defined activities, ‘monitorable’ targets and
budgets. In the case of multi-year projects,
it is important to include a provision to
undertake annual reviews which can form
the basis to revise the project.

•

requirements.

19

Process

•

Objective: Developing a feasible project
proposal.
Process owners: The implementation
agency (the CSR department, company
foundation or the NGO partner)

•

Inputs:
•

the CSR policy

•

institutional mechanisms

•

information from the government
sources, previous studies done in the
area, etc

•

information on programs targeting
similar geographies and beneficiary
groups or strategies

•

monitoring impact measurement
reports from any earlier projects

Output(s):

Detailing the project: the objectives,
the beneficiaries and the impact on
the beneficiaries, the assumptions,
the expected outputs and outcomes,
detailed activities, potential to
influence public policy and practice.
Identifying the indicators of success
with the means of verification and
establish the baseline for each. This can
be commissioned as a separate study
or can even be included in the needs
assessment stage.

•

Estimating the budget and how it will
be funded specifying the community
contributions, leveraging of the
government schemes and contributions
from the other donors.

•

Indicating the monitoring and
evaluation methodologies for impact
measurement.

A project proposal that details:


•

a project context including the roles of
other development actors

•

Social return on investments (SROI),
the SROI network

•

key needs of the target beneficiaries

•

•

project goals, KPIs, baselines and
expected end lines

Global impact investing network
(GIIN)

•

ISO 26000: social responsibility

•

project milestones for progress
monitoring purposes

Step five: Project approval

•

activities and timelines to achieve the
stated project goals

Purpose

•

budgets along with the basis for
estimation

•

risks and mitigation strategies

•

progress reporting: content, frequency

Activities:
•

Developing a framework to identify
key stakeholder groups including the
local community, the local government
or bodies, academia and research
institutions, investors, etc.

•

Conducting a needs assessment (if
required) to assess development
priorities. The methodology for this can
be participatory processes, surveys or a
combination of the two.

•

Studying and adopting good practices
to address similar challenges based on
prior experiences or lessons available
from other practitioners and develop
the approach.

Every project, whether developed by the
in-house team or an external agency, must
be formally examined and approved. This
is to ensure that each project is in line with
the CSR strategy and policy, the monitoring
indicators are clearly defined and relevant
and there is an adequate budget available.
Projects that go on for longer durations
or demand a larger amount of resources
must be scrutinised more carefully than the
others.
The CSR committee is ultimately the
one responsible for every project. It can,
however, choose to delegate authority to
a project approval committee consisting
of company staff and outside experts with
clearly defined roles and responsibilities.

Process
Objective: Approve the project based on
the CSR policy objectives, principles and
guidelines.
Process owners: The CSR committee or the
delegated project approval committee.

20 PwC

Inputs:
•

a project proposal

•


Output(s): An approved project proposal
including a monitoring process and
reporting and responsibility for this.
Activities:
•

Determining the delegation of power
for the project approval.

•

Establishing an evaluation framework
for the appraisal of the project concepts
and implementing agencies that ensure
complete alignment with the CSR
policy.

•

Establishing tests for the theory of
change; whether the concept will be
able to deliver the intended results.
Establishing tests for the value for
money, economy, effectiveness and
efficiency.

•

Reviewing risks and mitigation
measures.

•

Identifying resource availability
and any specific organisational
requirements and constraints.

•

Laying down organisational supervision
and oversight requirements.

•

requirements.

Step six: Finalising the
arrangement with the
implementing agency
Purpose
While working with an external agency,
it is very important to enter into a formal
arrangement which is referred to here
as a Memorandum of Understanding or
MoU. It defines the roles, responsibilities,
deliverables, commitments and
consequences in case of any breach. This is
essentially a formal acknowledgement that
all the partners have voluntarily consented
to work together to achieve an agreed
outcome that requires each one to play their
respective roles.
The term MoU is used more generically
here to refer to the arrangements between
partners which can range from a formal,
legally enforceable contract on the one hand
to a simple exchange of written documents

on the other. However, what is important
for the company to keep in mind is that
it is entering into an arrangement with a
partner, not a supplier and there is a greater
sense of mutuality in this relationship.
It may also be noted that the MoU is
relevant only if the project is being
implemented by a legal entity other than
the company’s own CSR department. It
must also be executed if the project is being
implemented by the company foundation if
it is a separate legal entity.

Disbursement scheduling
For a project to deliver the desired results,
it should have sufficient funds to carry out
the planned activities. At the same time,
having excess funds in the bank account
is not prudent financial management.
Thus, the scheduling of disbursements is
important both for the company (to plan its
cash flows from the CSR budget) and the
implementing agency and hence needs to be
detailed in the MOU.
A good practice suggests that the scheduling
of disbursements should be linked with
the activities planned for the each period;
this can be a quarter, six months or a
year depending upon the administrative
convenience and budget sizes. Thus, the
project budget needs to be broken up
accordingly and the funds required for the
subsequent period should be made available
in advance.
Actual disbursements have to then be linked
to the progress on the ground. The MoU
should also specify the conditions that the
implementing agency should fulfil and the
documentation it should provide in support
of a disbursement request. Typically, these
include the status of:
•

activities originally planned in the
period

•

changes and the reasons thereof

•

planned and required funds for the
period

•

utilised funds and bank balances

•

net funds required

Process
Objective: Agree upon and sign the MoU
with the partner.
Process owners: The CSR department or
company foundation
Inputs:
•

an approved project proposal

•


Output(s): MoU with the implementing
agency including the disbursement
schedule.
Activities:
•

Developing template MoUs based
on the context. Specify the outputs
and outcomes, the approach and
methodology, the KPIs, key parameters
to be monitored and reported, the
mode of communication, contract
management team, scope of change
in management procedures, dispute
or conflict resolution mechanisms,
inspection and audit requirements,
contract closeout requirements, timelines, milestones and deliverables,
budgets, process of invoicing and
release of payments, etc

•

Establishing a process for negotiation
of the MoU with the implementing
agency.

•

Negotiating, agreeing upon and signing
the MoU

•

requirements.

Step seven: Progress monitoring
and reporting

To ensure objectivity, it is critical that the
monitoring is done by someone other
than the people directly engaged in the
project implementation. In cases where
the implementation is done by a partner or
corporate foundation, this role can either be
outsourced or played by the company’s CSR
department. In case the CSR department
itself is implementing a project, then
monitoring should either be outsourced to
a third party or the department structure
should include an independent monitoring
cell. This decision should be taken by the
CSR committee.

Process
Objective: Monitoring progress, distilling
lessons and forming the basis for reporting.
Inputs:
•

The approved project proposal

•

Previous monitoring reports

Output(s):
•

Determining mid-course corrections

•

Recommendations for future project
designs

•

Project monitoring reports to the CSR
committee

Activities:
•

Determining the monitoring schedule
for each project based on the approved
project proposal.

•

Obtaining all relevant progress reports
from the project, studying them and
making a note of the gaps.

•

Holding discussions with the
implementation team on reasons for
slippages (if any) and agreeing on a
corrective action. This may be done
through a field visit or remotely, based
on what has been agreed in the MoU.

•

Holding discussions with the
implementation team regarding what
lessons are emerging and how they can
be applied within the project as well as
outside.

Purpose
Routine progress monitoring serves the
following three important purposes:
•

It highlights any slippages and helps to
determine a corrective action that must
be taken if need be.

•

It provides an excellent opportunity
for learning: what worked and what
did not. This can then be immediately
applied to other projects.

•

This is an essential part of the directors’
report as per the CSR clause of the
Companies Act, 2013

•

requirements.


21

Step eight: Impact measurement

Activities:

Purpose

•

Identifying methods for conducting
the impact assessment and outcome
measurement suited to the context
and the size of the project and budgets
available.

•

Identifying the skills set required for
the impact measurement team and
accordingly identifying, selecting and
appointing the team.

•

Assisting the team to prepare the
methodology for selecting a sample,
conducting surveys, focus group
discussions collecting information on
the identified indicators.

Impacts of the development projects
typically take a while to manifest. For
instance, a girl child education programme
can show an increased enrolment and
retention of girls and on a monthly basis,
but further impacts such as improved
learning levels will take at least a year.
So, impact measurement studies have
different objectives from project monitoring
and typically have to be undertaken after
providing sufficient time for them to
manifest.
Impact measurement is often quite
specialised and needs to be undertaken
by an independent team with specific
skills depending upon project design.
For instance, if a girl child education
programme has a strong component
for mobilising communities, then the
members of the evaluation team must not
only understand education but also have
knowledge of gender and the community in
order to assess the impact.
There are several tools and frameworks
for measuring impact. Each has its pros
and cons depending upon the nature of
interventions, time and budgets available
for the study and the availability of people.
Thus, selecting the impact measurement
methodology is important.
Thus, impact studies have to be carefully
planned in terms of team composition,
timing and methodology. The process must
be driven by the CSR committee which can
delegate the day-to-day management of the
process to an appropriate structure within
the company.

Process
Objective: Measuring the outcome and
impact of the projects.
Inputs:
•

resource planning

•

the project MoU

Output(s):
•

impact measurement report

•

recommendations for the future project
designs

22 PwC

•

Making the provisions for the site visits
by the team, involvement of the agency
involved during the baseline and needs
assessment.

•

Undertaking the impact measurement
exercise and preparing the report.

•

Identifying the lessons for future
interventions.

•

London Benchmarking Group(LBG)
model

•

Act, 2013. The report has to conform to
the requirements of CSR rules under the
Companies Act, 2013 in terms of form
and content as non-compliance attracts
penalties. This report will also form a key
input into the company’s SEBI Business
Responsibility Report and sustainability
report. The CSR committee may choose
to go beyond the requirements of the
Companies Act, 2013 and issue a standalone CSR report.

Process
Objective: Reporting the CSR at an
individual project level, consolidated at
a programme level and aligned with the
requirements under the Companies Act,
2013 and the CSR committee.
Process owners: The CSR department
Inputs:
•

CSR strategy and policy

•

the project MoU

•

monitoring reports from individual
projects

Output(s):
•

consolidated CSR reports

Social return on investments (SROI),
The SROI network

•

external stakeholder communication

•

Global impact investing network
(GIIN)

•

•

Accountability -: AA 1000, Institute
of Social and Ethical Accountability

Identifying the recipient of the report:
the board of directors, investors,
government agencies, beneficiaries, etc.

•

•

ISO 26000: social responsibility

•

Public consultation guidelines of
Government of India, etc

Selecting the appropriate reporting
framework that is aligned with the
requirements of the Companies Act,
2013 and the global best practices.

•

Consolidating project reports into
programme reports and an overall CSR
report.

Step nine: Report consolidation
and communication
Purpose
Reporting and communication closes the
loop between intent and achievement and is
hence a crucial element of the CSR process.
In the context of the Companies Act, 2013
this is also a mandatory requirement as it
provides crucial inputs to preparing the
directors’ report.
Project-level reporting forms the base
and hence getting it right is critical.
Project reports have to be consolidated in
programme related reports, aligned with
the CSR policy stated by the company
as a requirement under the Companies

Activities:

The reporting format will form a part of the
CSR rules being drafted by the Ministry of
Corporate Affairs.
•

SEBI directive on ESG disclosure (if
applicable) , RBI guidelines on CSR,
sustainable development and nonfinancial reporting (if applicable)

•

Clause 135, Companies Act, 2013 (if
applicable)

CSR and SMEs


23

CSR and SMEs
What are SMEs?
Small and medium enterprises (SMEs)
significantly contribute towards
India’s economic growth. These serve
independently and also as ancillary to larger
units and help generate employment and
industrialise the rural and backward regions
of India. They employ nearly 40% of India’s
workforce and contribute around 45% to
India’s manufacturing output20.

What do they do?
The business activities of SMEs are
performed in proximity to the locals. This
enables them to be aware of community
needs, manage expectations and develop
CSR programmes appropriately.
Now that the CSR clause in the Companies
Act, 2013 covers companies that have a
turnover of five crore INR and above, it
is expected that while micro-enterprises
will not qualify, many small and medium
enterprises (SMEs) will.
SMEs are being treated separately in this
handbook because of their distinct features.
The CSR activities of these enterprises
are driven by the personal interests of
promoters who hold a significant financial
stake in the business. They tend to be in
clusters and engaged in similar business
activities. While the quantum of revenue
available for CSR with individual SMEs is
expected to be small, all eligible companies
in a specific geographical cluster, who single
handed as well as collectively impact the
same community, can pool their resources
to create a sizeable CSR fund.

Why collaborate for CSR
initiatives?
CSR is for all companies. SMEs in India
have participated in CSR activities but these
efforts have not been optimally delivered.21
One possible reason can be the fact that CSR
activities depend on the profits of an SME
and any fluctuations in profits can adversely
affect their capability to continue their
contribution for CSR. Another reason can
be the limited human resources available to
SMEs which may also result in the lack of a
professional approach.
SMEs tend to focus on short-term activities
that involve lesser operational costs. A
survey conducted by UNIDO in 2008 on five
SME clusters in India, found that 31% to
79% of the SMEs in these clusters, preferred
charity donations rather than long-term
programmes for local communities.
With the introduction of the new Companies
Act, 2013, the SME’s approach to CSR has
to be modified while keeping operational
costs low. One viable alternative is to pool
resources with other SMEs in the cluster
and create joint CSR programmes managed
by a single entity. This collaboration can be
formed within the units in a cluster as they
interact with the same communities and
have already established associations that
cater to the business needs of the units.
Collaboration has the following
advantages:
•

Reduces operational cost: Individual
CSR efforts by a company consist
of establishing a CSR department,
assessing the needs of local
communities, undertaking programmes
directly or through an NGO and
conducting regular impact assessment
studies. A common organisation
catering to a number of companies will
carry out these activities collectively
and thus reduce the operational cost of
management.

•

Undertake long-term projects: A
major hindrance in developing longterm projects is the uncertainty in the
CSR budget. This is dependent on the
financial performance of the company.
A fluctuating performance implies
that the CSR budget allocations can
be unreliable and can jeopardise a
programme initiated earlier. Pooling
resources addresses this issue to a

How can SMEs contribute to CSR
initiatives?
This section analyses the option of
undertaking collaborative CSR activities
by SMEs. This collaboration can also be
used by other companies to maximise
the impact of their CSR initiatives while
reducing the operational costs for fund
management.

20. http://articles.economictimes.indiatimes.com/2013-06-09/news/39834857_1_smes-workforce-small-and-medium-enterprises
21. http://www.business-standard.com/article/sme/smes-to-get-professional-help-on-corporate-social-responsibility-108060501090_1.html

24 PwC

certain extent as the other partners
can increase their share in case there
is variance in allocation from a certain
segment of the cluster. The longterm programmes also have greater
impact than the short-term projects.
Communities are increasingly realising
the importance of the support offered
by these programmes in making their
lives better. Long-term programmes
also lead to better community relations
and this ensures avoiding situations
of community unrest that hamper
business activities.
•

Learning from experiences: A common
entity with multiple participants from
the cluster will help assess community
needs, undertake relevant programmes
based on past experiences and address
a greater number of community issues.

Collaboration among the SMEs in a cluster
also provides an opportunity to manage
social and environmental issues and
respond better to the pressure from buyers,
who are trying to establish ethical supply
chains and gain appreciation from the
international community. Collaborations
can also be forged amongst larger
companies, possibly through industry
associations, to enable them to address
common issues plaguing a geographical
region or an industry.

The process for an SME
The first step involved in collaborating is to
create an alliance of interested SMEs. This
may be initiated by the cluster association
in case of large-scale participation from the
cluster. Alternatively, it can be initiated by
an individual SME in case there are only
a few units interested in undertaking CSR
activities in collaboration. Involvement of
the cluster association will ensure that the
local priorities are given due consideration
while developing CSR programmes. In case
a sufficient number of SMEs in a cluster do
not wish to participate or are not required
under the Companies Act, 2013 to spend
on CSR activities, the boundary may be
extended to other clusters, though this
increases complexity.
The alliance should then form a steering
committee with the representatives from
each SME so as to democratically decide on
issues. The steering committee should study
the institutional method of implementation,
i.e. undertaking activities through an
established trust, society, a Section 8
company or forming a new entity or directly
managing the funds.

The steps other than the guidelines
mentioned by the steering committee in the
section “CSR: Planning and strategising” of
this handbook, include the following:
•

Deciding the thematic areas from
Schedule VII of the Companies
Act, 2013, beneficiary groups and
geographies that it will target based on
the inputs from participants.

•

Developing internal processes to track
individual contribution by members
and their utilisation in CSR activities,
finalising long-term projects based on
projected contributions by members
and addressing non-payment by
members.

The CSR policy of individual SMEs should
be designed to allow for flexibility in case of
a collaborative effort to undertake CSR. This
implies that the policy, over and above the
guidelines mentioned in the section “Step
one: Develop CSR strategy and policy”,
should allow the following:
•

Flexibility in selecting thematic areas
from Schedule VII of Companies
Act, 2013, beneficiary groups and
geographies as per the priorities of the
entire association.

•

Support to initiate CSR programmes
to the extent possible, in case the
association is abandoned.

The next steps involved in the due
diligence of implementation or the concept
development partner are:
•

Project development

•

Operationalising institutional
mechanism

•

Contracting

•

Budgeting and payments

•

Monitoring

•

Impact measurement

Reporting and communication are as
described in section “CSR: Planning and
strategising”
In cases where the total CSR funds
are insufficient to cover the cost of
collaboration, SMEs can also contribute to
the Prime Minister’s National Relief Fund
or any other fund set up by the central
government or the state governments as
per activity ix of the Schedule VII of the
Companies Act, 2013.


25

Appendix 1
Comparative analysis of the three choices for legal entity

Differential factors

Trust

Society

Section 8 company22
(earlier known as Section 25 company)

Basic document

Trust deed which contains objects of
the trust (bye-law)

Memorandum of association
Articles of association with rules and
regulations

Memorandum of association
Articles of association

Formation

Simple

Simple

Slightly difficult

Jurisdiction

Deputy registrar or charity
commissioner

Registrar of Societies

Registrar of Companies

Legislation / statute

Relevant state trust act

Societies Registration Act 1860

Companies Act 2013

Objectives

Social benefits and charitable

Literary, charitable, scientific and
resource oriented

Nonprofit activities

Re-amendment
or modification of
objects

Alteration can be undertaken only
by the founder or settler

Easy, legal procedures

Complicated, legal procedures

Required members

Minimum = 2, maximum = no limit



Registration

As trust with the registrar

As society with society registrar

As per Companies Act under Section 8 (earlier
Section 25)

Stamp duty

4% of trust property value will be
executed in non judicial stamp paper
with the registrar

No stamp paper required for
memorandum of association, and
rules and regulations

No stamp paper required for memorandum and
articles of association

Name

Easy to choose

Easy to choose

Prior approval required from Registrar of
Companies

Management board

Trustees

Governing body

Board of directors and management
committee

Succession in
management

By election

By election

By appointment

Meetings

No provisions

Annual meeting as per law,
governing body meeting as per the
rules of society,

Quite extensive as per the provision of
Company Law

Statutory regulations

Nominal

Limited

Maturable and exhaustive

Membership transfer

Not possible

Not possible

Free or control as per desire

Member admission

Not applicable

Governing body control

General body or board control through issue
of capital

Payment to members

As notified in trust deed

Not restricted

As approved by company and state

22 The non-profit organizsation formerly known as Section 25 companies are now called Section 8 companies after the introduction of Companies Act,
2013.

26 PwC

Appendix 2
Designing a volunteering programme

As part of their corporate social
responsibility efforts, companies encourage
their employees to volunteer for a cause
(usually pre-selected by corporate
human resources or foundations) during
work hours under formalised employee
volunteering programmes (EVPs). These
EVPs involve substantial opportunity
cost for employers and therefore must be
carefully planned and executed.

Design parameter

Activities

Organisation goals: Laying out the overall
objective of a company from its EVP.

• Identify volunteering goals of your
organisation.

Employee volunteering mechanism:
Developing the institutional framework under
which employee volunteerism can be channelled
for a larger good.

• Establish institutional ownership of
volunteering programme.
• Establish volunteer codes of practice.
• Establish volunteering governing principles.
• Design volunteer programmes and projects.
• Draft volunteering agreement including
the statement of volunteer rights and
responsibilities.
• Lay out roles and responsibilities of
coordinators for the EVP.
• Ensure continuity in volunteer work.

Recruitment and enrolment: Attracting,
screening and selecting qualified individuals for
a specific volunteer role.

• Lay out the volunteer recruitment and
enrolment process.
• Create volunteer roles and writing position
descriptions.
• Segment and target volunteers.
• Write volunteer advertisements.
• Process enquiries and applications.
• Undertake selection and interview process.

Most often, there are no financial gains
for the work or service provided by such
volunteers. However, sometimes this
volunteering involves incentives such as
personality or profile development, skill
development, socialisation, and fun. In
certain areas of volunteering work such as
health services, education or emergency
rescue volunteers receive training before
they can contribute.

Inducting and training: Welcoming new
volunteers to the EVP and preparing them for
their role. It provides an introduction to the
working environment where they will volunteer
and available resources. The process will cover
volunteer rights, the terms and conditions of
volunteering, legal and compliance requirements
and health and safety guidance. It also covers
any necessary training needs of the volunteers to
perform their duties.

• Design and deliver induction and orientation
programmes.
• Train volunteers.

However, most volunteers serve on a need
basis without any prior educational or work
experience of related background.

Mentoring and supervising: Ad hoc assistance
by a more experienced and knowledgeable
person to help facilitate a less experienced
and knowledgeable person to reach his or
her individual goals and objectives in the
volunteering programme. Supervision involves
management of the individual’s performance
against a prescribed objective on a routine basis
and providing actionable feedback.

• Design and deliver mentoring programme.
• Assign, supervise and establish key
performance indicators for volunteer work.
• Provide performance feedback to volunteers.
• Keep volunteers motivated.
• Manage disputes and grievances.

Rewarding and recognising: Rewards and
recognition are given when an organisation
wants to motivate volunteers in achieving a
goal or organisational objective. Rewards and
recognition are designed to distinguish and
motivate employees. This is important in the case
of volunteering where employees do not have
any financial incentives.

• Make volunteering attractive.
• Develop awards and recognition framework.

Encouraging diversity: Encouraging employees
with unique experiences and backgrounds
to work together to increase productivity,
effectiveness and responsiveness to changing
conditions to enhance their contribution and
benefit from the volunteering exercise.

• Communicate the value of diversity.
• Develop programmes to encourage diversity.
• Recruit and enroll volunteers from diverse
backgrounds.

Who is a corporate
volunteer?
A corporate volunteer is an employee who
actively takes on a task, responsibility, or
project on his or her own accord without
needing to be assigned or told to do so as
part of his or her daily job duties. Corporate
volunteering is generally considered an
altruistic activity and is intended to promote
larger social or environmental good or
improve the quality of life of a target
beneficiary or a community.

Several design parameters and related
activities need to considered while
developing an EVP:


27

Appendix 3
Community engagement

A community can be defined as a
homogenous group of individuals bound
together geographically, politically,
culturally or by certain values, principles or
shared characteristics. For the purposes of
this discussion, we define community as the
collection of stakeholders who reside in the
local vicinity of company operations and
who rely on or are impacted by its shared
resources.
Community engagement is defined as
a process in which the needs, priorities
and values of various individuals (not
directly associated with or dependent
on a given company) and that of other
external organisations in a community
are incorporated into corporate decisionmaking and management activities.
•

Steps for robust community engagement

Key activities

Assess the local context: Understanding the
characteristics and complexities of the local
landscape and use this information for strategic
planning of community engagement.

• Undertake socioeconomic assessment.
• Map local communities and networks.
• Map key institutions engaged with local
communities.
• Identify potential partners.

Involve communities: Support and facilitation
of the process of community-driven planning to
enable communities to define their own goals,
identify opportunities and assets they plan to
utilise or share, and prioritise areas of potential
engagement with the company and other local
development actors.

• Identify objectives of community engagement
and its guiding principles.
• Enable community planning, visioning and
prioritisation through participatory methods.
• Manage community expectations and
perceptions.

Identify and categorise key stakeholders:
• Identify and segment various target groups.
Creation of a list of the individuals, groups, and
• Undertake needs assessment.
institutions that could affect or be affected by any
community engagement project. This step identifies and generates knowledge about individuals
and local organisations in order to understand
their behaviours, intentions, inter-relations and
interests.

Participatory rural appraisal

•

Focus group discussions

•

Door-to-door surveys

Set operational parameters: Setting up the
scope and target of such an engagement in line
with the activities a company will support.

Project implementation: Identifying the
best way to deliver a project in view of several
variables, such as the objectives of community
engagement, project timeframe, budget and local
operating context.

Measure and communicate results: Monitoring
and evaluation to use the information collected
in future planning and communicating these
results to all stakeholders including the community, the company and other development
partners.

28 PwC

• Develop a baseline.
• Identify the company and any shared assets
available.
• Identify investment areas and budgets.
• Develop key performance indicators.
• Select implementation model: in-house or
foundation, implementation partner, multistakeholder partnership, any other hybrid
model.
• Engage and influence key opinion leaders in
local community.
• Develop community forums.
• Invest in capacity building of community.
• Co-design detailed development projects with
community participation.
• Operationalise development projects and
manage project cycle.
• Document results on key performance
indicators.
• Calculate social return on investments.
• Develop communications strategy to
periodically disseminate information to
community and other stakeholders.

Appendix 4
CII and Credibility Alliance’s guidelines for identifying NGO partners

1. Identity: The NGO should exist and be
registered under the appropriate law
under which it is governed. It should
comply with the provisions of the Act
and other relevant laws.
•

•

The organisation is not for profit and
its resources are deployed only for
accomplishing the objectives for which
it has been formed.

•

The organisation has attained
recognition under Section 12A of the
Income Tax Act. (80G of the Income Tax
Act is preferable).

The organisation has been functioning
for a minimum of one year from the
date of registration.

•

The physical address given by the
organisation is verifiable.

•

The organisation is registered as a trust
or society or Section 25 company.

•

•

Registration certificates and documents
issued by the appropriate authority are
available upon request.

The board approves programmes,
budgets, annual activity reports and
audited financial statements.

•

The board ensures the organisation’s
compliance with applicable laws and
statutory regulations.

•

Signed audited statements are prepared
annually and available on request:
balance sheet, income and expenditure
statement, receipts and payments
account, schedules to these, notes on
accounts and the statutory auditor’s
report.

•

Statement of accounts indicating
whether constructed on a cash or
accrual basis.

•

There are no serious adverse notes on
the veracity of the functioning of the
organisation.

•

There are no material transactions
involving conflict of interest between a
board or staff member and/or adverse
comment and observation relating to
operational issues or financial dealing
in the record of public authority.

•

The organisation’s annual report is
distributed and communicated to
stakeholders and others and is made
available upon request every year,
within eight months of the end of the
organisation’s financial year.

•

The annual report contains a
description of the main activities, a
review of the progress and results
achieved in the year and information
on board member names, positions,
remuneration or reimbursement as well
as brief financial details.

•

The NGO shall disclose their funding
details i.e. the sources of funds,
annual revenue (O&M) and project
expenditure. The organisation shall
produce timely reports on the use and
management of funds which should be
made available on request.

•

Dovetailing with government schemes
will be preferred.

•

The NGO should give out accurate
information regarding their projects
i.e. survey reports, target population,
location, sustainability of the projects,
their success ratio, etc on request.

Minutes of board meetings are
documented and circulated.

•

•

All pending legal disputes are declared.

2. Vision, aims, objectives,
achievements: The vision, purpose and
aims of the NGO should be explicitly
stated and be reflected in the activities
being undertaken.
•

A vision, purpose or mission, which
drives the organisation, is articulated
beyond the registration documents in
the form of activities and projects, etc.

•

The organisation has a defined aim and
a set of objectives.

•

The organisation is able to show
performance through defined indicators
against stated objectives.

3. Governance: There must be a
clear commitment towards good
governance for the NGO to enhance its
effectiveness, serve all stakeholders,
meet the needs of society and to ensure
its accountability towards society in
accordance with its charter of objects
and purposes.
•
•

•

•

The organisation has a governing
board.
The organisation follows a consultative
and democratic decision-making
process.
There is disclosure of the details of
board members viz, name, age, gender,
position and occupation. All family
affiliations should be indicated.
The board has at least two meetings
a year suitably spaced with quorum
stipulated in its own articles of
association, reviewing the functioning
of the NGO, evaluating the projects
undertaken by them and discussing the
way forward.

4. Operations: Operations refer to the
capacity to conduct programmes and
administrative activities efficiently and
effectively in the public interest. The
NGO should have norms in respect
to the nature of the programme it
undertakes, the nature and style of
its management; and the roles and
responsibilities of its human resources
including personnel and volunteers.
•

The activities are in line with the vision,
aim and objectives of the organisation.

•

The organisation periodically reviews
the progress of programmes.

•

The accounts of the organisation are
regularly maintained and those with an
annual income above 50,000 INR are
audited by the chartered accountant.

•

The roles and responsibilities
are defined for all personnel and
volunteers.

•

All personnel are issued letters of
contract and appointment.

•

An appropriate HR policy is in place.

5. Accountability and transparency:
Accountability and transparency are
key requirements of good governance
and necessary for building trust among
stakeholders. This works as a testimony
to the fact that the organisation has
been working efficiently and effectively.
•

The organisation should be ready to
submit an affidavit by the authorised
signatory attesting to the authenticity of
the information given.

A financial management policy has
been developed and is adhered to.


29

Appendix 5
Illustrative list of NGOs and platforms for information on NGOs prepared by CII

1.

GiveIndia (http://www.giveindia.org/): GiveIndia is a donation platform that
allows companies to support a cause of choice from about 200 NGOs that have been
scrutinised for transparency and credibility.

2.

Voluntary Action Network India (http://www.vaniindia.org/): Voluntary Action
Network India works towards building a society where voluntarism and voluntary
organisations play a dominant role in social cohesion, economic empowerment and
nation-building.

3.

Charities Aid Foundation (http://www.cafindia.org/): CAF India provides strategic
and management support to corporates, individuals and PSUs in order to ensure
greater impact of their philanthropic and CSR investments.

4.

Oxfam India (http://www.oxfamindia.org/): The Oxfams are rights-based
organisations that fight poverty and injustice by linking grassroots programming
(through partner NGOs) to local, national and global advocacy and policy-making.

5.

Confederation of Voluntary Associations (covanetwork.org/): COVA works in the
areas of communal harmony, peace and social justice through sensitisation of all
sections of society and empowerment of the marginalised and the poor.

6.

Partners in Change (http://www.picindia.org/): PiC focusses on building sustainable
partnerships between the corporate sector and social development initiatives in India.
PiC’s goal has been to become an organisation that is recognised both by companies
as well as civil society as a reliable facilitator for building partnerships for social
development.

7.

Credibility Alliance (http://credibilityalliance.org): Credibility Alliance’s mission is to
build the credibility of the voluntary sector through the creation and promotion of the
norms of good governance and public disclosure.

8.

Samhita (http://samhita.org/): Samhita provides a platform for NGOs to showcase
their work and attract donation.

9.

Indian Confederation of NGOs (http://www.icongo.in/): iCONGO is a collective of
various credible, transparent and accountable NGO members registered as promoting
members and privilege members.

10. GuideStar India (http://www.guidestarindia.org/): GuideStar India is India’s leading
provider of NGO information. Their portal provides a fully searchable database of
reliable and comparable information on over 3,500 NGOs.

Handbook on CSR in India

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